Readers’ forum: Mixed supply?

I act for a VAT registered client who has imported some gift boxes from China. He will put ten samples of good quality cheese inside each box and sell the completed item to both retailers and also directly to UK customers through his website. The final selling price will be £23 a package. The presentation box will include the company’s name and logo on it in gold-coloured lettering with the heading of ‘fine cheese selection’.

My concern relates to VAT. My client’s view is that the sales will all be zero rated because if there was no cheese in the box the customers would not buy the product – and cheese is zero rated as food. He has compared it with someone buying a ticket to go inside a football stadium when there is no game taking place. But I am not so sure – the boxes...